Transcript Document
NSPS Regulations Update Angela Marconi, P.E., BCEE Manager of Landfill Gas Systems Delaware Solid Waste Authority **WARNING** 2 Introduction & Background • New Source Performance Standards (NSPS) • Existing Guidelines (EG) and Compliance Times for Municipal Solid Waste Landfills • Current NSPS & EG were both issued March 12, 1996 • They are subparts: – WWW (NSPS) – Cc (EG) 3 Introduction & Background • On July 17, 2014 a proposed new NSPS (subpart XXX) & ANPRM were issued • Advanced Notice of Proposed Rulemaking (ANPRM) for the revised EG • SWANA submitted comments on both September 15, 2014 • EPA plans to finalize the NSPS 2015 • EPA plans to propose the EG 2015 and finalize it in 2016 4 5 Applicability • Subpart XXX will apply to landfills that are newly constructed, modified or reconstructed after July 17, 2014 • Once final, the EG may include many Subpart XXX requirements that will apply to existing landfills 6 Proposal • Subpart XXX contained an extensive preamble requesting answers to questions and requests for suggestions • ANPRM was “all preamble” • RED = proposed • GREEN = questions • BLUE = SWANA comments 7 Threshold Reduction 40 MG/yr. NMOC 8 Treatment • Prescriptive Requirements Proposed: – 10 microns for filtration systems – 45°F for temperature – Continuous monitoring at 15 minute intervals using 24 hr. avg. to monitor pressure drop for filtration and dew point drop for temperature 9 Treatment • Temperature requirement is an increased burden • Majority of projects do not require chillers; addition is major cost • Pretreatment should be based on equipment manufacturer guidelines • SWANA: No continuous monitoring requirement; compliance through operations and maintenance records in semi-annual reports 10 Wellhead Standards • Proposed: Maintain existing performance standards for temperature and oxygen or nitrogen • Comment: Eliminate standards; can hinder efficient operation of GCCS and hamper emission reductions 11 Wellhead Standards • Reduce oxygen & temperature monitoring frequency? • Adjust monitoring frequency only for beneficial use sites? • Require automated wellhead monitoring? • Additional parameters? 12 Best System of Emission Reduction • Proposed: Well-designed and operated GCCS is best system of emission reduction (BSER) • Comment: Agree with definition of BSER – Prescriptive requirements counter to BSER – Open/non-enclosed flares should remain BSER 13 Surface Emissions Monitoring • Preamble Clarification: SEM is required at every penetration • Comment: This has not been the previous policy • Targeted approach where problems are likely – Visual or olfactory observation (e.g., stressed vegetation) – Clarification Requested: Monitoring every penetration not required under WWW 14 Surface Emissions Monitoring • Solicitation of information to bring SEM to look more like the California Landfill Methane Rule (LMR) – Tighter walking pattern & integrated monitoring? – Incorporate wind speed restrictions for SEM? • Comment: Maintain WWW SEM criteria – Data from California has shown minor benefits of enhanced SEM does not warrant the effort/cost. • EPA estimated annual cost increase of $50,000 to $362,900 – 73% of sites have requested a weather variance 15 Surface Emissions Monitoring • Remote measuring & monitoring? – – – – – – – – – Radial plume mapping Optical remote sensing Fourier Transform Infrared spectroscopy Cavity ringdown spectroscopy Tunable diode laser Tracer Correlation Micrometerological eddy-covariance Static flux chamber Differential absorption 16 Surface Emissions Monitoring • Comment: Maintain current SEM as BSER – Enhance monitoring significant increased cost – Implementation & logistical issues – These are research tools only 17 Startup, Shutdown & Malfunction • Proposed: Eliminate 1-hour and 5-day downtime criteria; NSPS applies at all times • Comment: The nature of landfills makes this impossible to meet – Only emission standard: reducing NMOC by 98% – Landfill a sponge if GCCS down, emissions not automatic – Difficult to quantify emission exceedances 18 Startup, Shutdown & Malfunction • Practical Impact of SSM Elimination: – 5-Day provision gone; GCCS downtime could be a deviation – 1-Hour provision gone; device downtime could be a deviation – Device temperature variations during startup/shutdown could be a deviation – Enhanced enforcement/fines/chronic violation – Permit/Title V issues 19 Closed & Non-Producing • Proposed: Actual data rather than estimated emissions criteria for meeting 1% NMOC GCCS removal • Comment – Support use of actual data – Additional flexibility needed for closed/nonproductive sites 20 Closed & Non-Producing • Clarify NSPS to apply to closed areas of active landfills • NSPS 15 year removal date from initial well installation, not NSPS/EG performance test • Annual SEM for closed areas of active landfills • Tier 2,3,“4” allowed at any time to defer NSPS 21 Tier 4 • “Tier 4” for determining when GCCS is installed? • Comment: Support “Tier 4” procedure – Using SEM to determine installation requirement – Allow non-producing areas of active landfills – Use a similar step-down to exit NSPS 22 Definition of Household Waste • Proposed: Excludes segregated yard waste; preamble clarifies C&D as not in HHW definition • Comment: Support segregated yard waste exclusion; recommend C&D clarification added to definition 23 Additional Items • NSPS – Design plan approvals – Test Methods 18 & 25A removed from use • ANPRM – – – – – Waterlogged wells Redundant seals & enhanced sealing materials Biocovers/biofilters Emissions modeling Organics Diversion 24 Summary • Stay tuned for final XXX and proposed EG • When the rules come out read them (or assign this to a subordinate) 25 Questions? Angela Marconi: [email protected] Manager of LFG Operations, Delaware Solid Waste Authority 26